https://www.taxtmi.com/caselaws?id=19080 HC held that reassessment notices issued under section 148 were invalid for all relevant assessment years. For earlier years, the Assessing Officer had been fully informed of the method of allocation of headquarters expenses, so reopening was based merely on a change of opinion, not on any failure to disclose material facts. For subsequent years, an inadvertent misallocation of overseas headquarters expenses was voluntarily disclosed by the assessee, with additional tax paid on self-assessment, negating any allegation of omission or suppression. Section 147(a) was therefore inapplicable, and the Commissioner's sanction for reopening was unjustified. The appeals were dismissed and the notices quashed. en-us Wed, 21 Jul 1993 00:00:00 +0530 Fri, 12 Dec 2025 19:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19080 HC held that reassessment notices issued under section 148 were invalid for all relevant assessment years. For earlier years, the Assessing Officer had been fully informed of the method of allocation of headquarters expenses, so reopening was based merely on a change of opinion, not on any failure to disclose material facts. For subsequent years, an inadvertent misallocation of overseas headquarters expenses was voluntarily disclosed by the assessee, with additional tax paid on self-assessment, negating any allegation of omission or suppression. Section 147(a) was therefore inapplicable, and the Commissioner's sanction for reopening was unjustified. The appeals were dismissed and the notices quashed. Case-Laws Income Tax Wed, 21 Jul 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19080